2011-02-15_REVISION - C1980004 (2)

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i STATE OF COLORADO Bill Ritter, Jr., Governor DEPARTMENT OF NATURAL RESOURCES DIVISION OF WILDLIFE AN EQUAL. OPPORTUNITY EMPLOYER Thomas E. Remington, Director 6060 Broadway Denver, Colorado 80216 Telephone: (303) 297 -1192 wildfife.state.co.us Northwest Region Service Center 711 Independent Avenue Grand Junction, CO 81505 (970) 255 -6100 O' ar'd g�EMI jI of For Wildlife - For People January 6, 2011 D- ivistah.,af. Reclamation, Mining and Safety Department of Natural Resources Attn: Michael P. Boulay, Environmental Protection Specialist 1313 Sherman St., Room 215 Denver, CO 80203 Re: McClane Canyon Mine (Permit No. C- 1980 -004) Permit Revision (PR2) Expansion of Surface Facilities and Mining Plan Dear Mr. Boulay: The Colorado Division of Wildlife has reviewed the McClane Canyon Coal Mine Waste Rock Disposal Site and Coal Storage Area Wildlife and Sensitive Plan Studies, dated October 2010 for the McClane Canyon Mine (Permit No. C- 1980 -004), Permit Revision (PR2), Expansion of Surface Facilities and Mining Plan. Since the report did not address operational details of the coal mine facility and operations, our comments are limited to the evaluation of the biological data collected. In general, we feel that the wildlife occurrence data related to terrestrial wildlife was well done. Your conclusions regarding the current state of the vegetative community are accurate. We are pleased to see the updated section on bat species, as suggested by the CDOW in our letter dated 16 July 2010, has been included in the most recent report; however, we feel that the aquatic sections of the report are still lacking detail on species occurrence and abundance. The inventory section of the CAM report mentions results from the CDOW's 2010 sampling of East Salt Creek. CAM makes the statement within this section of the report that impacts to fish may or may not occur within % mile of the project area. However, the report fails to provide documentation as to why impacts will be limited to the extent claimed by CAM except that no fish have been documented by sampling above the mine. • Given the complex nature of perennial and ephemeral streams and arid drainages — the high conductivity of the water and the variability in temporal and spatial biological communities of the streams — CAMs assertion of "unlikely impacts to aquatic resources" is a claim unsupported by adequate documentation. DEPARTMENT OF NATURAL RESOURCES, Mike King, Executive Director WILDLIFE COMMISSION, Tim Glenn, Chair • Robert Streeter, Vice Chair • Mark Smith, Secretary Members, David R. Brougham • Dennis Buechler • Dorothea Farris • Allan Jones • John Singletary • Dean Wingfield Ex Officio Members, Mike Kng and John Stulp